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Minimum Equity Standard

The Climate and Equitable Jobs Act (CEJA) directed the Illinois Power Agency to create an Equity Accountability System establishing equity requirements, including the Minimum Equity Standard (“MES”), in certain IPA programs and procurements. The purpose of the MES is to expand access to employment and business opportunities in Illinois’ clean energy sector for communities that have historically been excluded from these opportunities. Beginning June 1, 2023, an increasing portion of the work on renewable energy projects supported by IPA’s Illinois Shines Program, self-direct program, or utility-scale renewable energy procurements must be performed by Equity Eligible Persons (EEPs) or Equity Eligible Contractors (EECs). Starting June 1, 2026, Public Act 104-0458, the Clean and Reliable Grid Affordability Act (CRGA), expanded MES requirements to Illinois Solar for All (ILSFA) and utility-scale energy storage procurements.   

An Equity Eligible Person (“EEP”) is a person that “would most benefit from equitable investments by the State designed to combat discrimination.” An individual can qualify as an EEP if they meet any of the following criteria: 

  • Graduates or current or former participants in the Clean Jobs Workforce Network Program, Clean Energy Contractor Incubator Program, Illinois Climate Works Pre-apprenticeship Program, Returning Residents Clean Jobs Training Program, or the Clean Energy Primes Contractor Accelerator Program, and the solar training pipeline and multicultural jobs program created by Future Energy Jobs Act;  

  • Persons who are graduates of or currently enrolled in the foster care system; 

  • Persons who were formerly incarcerated; or  

  • Persons whose primary residence is in an equity eligible investment community. 

Registration of Equity Eligible Persons

All entities participating Illinois Shines, Indexed REC Procurements, Energy Storage, or that have chosen to meet the MES as their workforce requirement in ILSFA, are required to meet the Minimum Equity Standard through registering EEPs in their workforce. For Program/Delivery Year 2026-2027, the MES percentage is 14% for Shines and ILSFA, and for Indexed REC projects, it is dependent on the seller contract. 

As your organization hires and/or works with Equity Eligible Persons (EEPs) during the program/delivery year, please keep in mind that the Agency will require data for these individuals during MES reporting at the end of the year through the MES Combined Compliance and Year-End Report. The Agency verifies EEP eligibility as part of the review process for this report. Entities have two options for providing this data.

EEP Registration Through the Energy Workforce Equity Portal    

  • The entity can either encourage all EEPs in their project workforce to register in IPA’s Energy Workforce Equity Portal, or register for them on their behalf: https://energyequity.illinois.gov/ 
  • This option allows the entity to simply provide the names of the registered EEPs in its MES Combined Compliance and Year-End Report.
  • To register EEPs on their behalf through the Equity Portal, entities must have applicable documentation (described below) and each EEP-eligible individual fill out and sign an attestation form: EEP Attestation

EEP Manual Registration Through Combined MES Compliance Plan and Year-End Report Process

  • For this option, the entity can collect signed EEP attestations and provide any required documentation for their EEPs through the Year-End Report portion of the Combined MES Compliance and Year-End Report. The EEP attestation can be downloaded here: EEP Attestation
  • This option requires that the entity collect required supplemental documentation for EEPs who qualify based on graduation from a participating workforce training program, or whose primary residence is located in an Equity Investment Eligible Community. Acceptable documentation is described below. All personally identifying information and private information will be held confidential. 

Documentation (required for both registration options) 

  • For EEPs who qualify based on graduation or current participation in a qualifying workforce training program, please provide either an acceptance letter from the training provider (for current participants), or a certificate of completion from the training provider (for graduates). 
  • For EEPs who qualify based on primary residence, please provide the individual’s driver’s license, state ID, utility bill, lease, or mortgage agreement for the Agency to verify the individual’s eligibility

The IPA Act defines “equity eligible contractor” (“EEC”) as “a business that is majority-owned by eligible persons, or a nonprofit or cooperative that is majority-governed by eligible persons, or is a natural person that is an eligible person offering personal services as an independent contractor.”

To become an EEC, visit the Illinois Shines Become an EEC Page.

Program Specific MES Resources and Information

A Minimum Equity Standard of 10% will apply under the 2026 Indexed Storage Credit (ISC) Contract to all energy storage projects selected through the August 2026 procurement. This means the project workforce for projects awarded a contract in the August 2026 procurement is required to be comprised of at least 10% EEPs. The MES percentage may increase for projects participating in future procurements. The MES applies for each delivery year in which Construction Activities are performed through the project’s Commercial Operation Date.

For information on MES requirements for utility-scale energy storage projects, review Section 6.4 of the ISC Contract and the Energy Storage page of the IPA website. 

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Projects participating in applicable utility-scale renewable energy procurements are subject to the Minimum Equity Standard established in their Indexed REC Contract. The required MES percentage is determined by the delivery year in which the procurement occurred. The applicable MES percentage represents the minimum percentage of the project workforce that must consist of EEPs or EECs.  The MES applies for each delivery year in which Construction Activities are performed through the Date of First Operation, or if the Project is a Modernized or Retooled Hydropower Project through the Hydropower Refurbishment Completion Date. The schedule below identifies the MES percentage applicable to projects selected through each procurement.

MES Requirement Schedule by Contract:

 
 Delivery Year   Scheduled MES increase   % Increased
 2024-2025  10%  - 
 2025-2026  14%  4%
 2026-2027  14%  - 
 2027-2028  18%  4%
 2028-2029  22%  4%
 2029-2030  26%  4%
 2030-2031  30%  4%

For more information on MES requirements for utility scale renewable energy procurements, please visit the Indexed Wind, Solar, Brownfield, and Hydropower page on the procurement website and the Utility-Scale Projects page on the IPA website.

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Each Program Year in Illinois Shines, the project  workforce of each participating Approved Vendor and Designee must be comprised of a required minimum percentage of EEPs or EECs, with this required percentage increasing to 30% by 2030. Compliance with the Minimum Equity Standard is demonstrated and reported by program participants through the MES Combined Compliance and Year-End Report. Future Program Years’ percentages are determined by the IPA and presented through updates to the Long-Term Renewable Resources Procurement Plan.

For information on MES requirements for projects participating in Illinois Shines, visit the Minimum Equity Standard page of the Program website.

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Illinois Solar for All requires that Approved Vendors meet workforce requirements across their portfolio of projects and pay the applicable prevailing wage rate to workers employed on certain ILSFA projects. Public Act 104-0458, known as the Clean and Reliable Grid Affordability Act (CRGA), added language that amends workforce requirements for the Program by providing ILSFA Approved Vendors the option to either comply with the Minimum Equity Standard (MES) or the existing ILSFA job training requirements, starting in Program Year 2026-27. 

At the start of each Program Year, Approved Vendors are required to identify which workforce requirement they will comply with, either job training or MES; any change to this designation may only be made at the beginning of a new Program Year when filling out the MES Combined Compliance and Year-End Report. All Approved Vendors should fill out and submit the first portion of the Combined MES Compliance and Year-End Report, which confirms their selected workforce track for the Program Year. 

Approved Vendors choosing to comply with the MES must ensure their project workforce is comprised of the required minimum percentage of EEPs or EECs.

For more information, visit the Illinois Solar for All page. 

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